1 | Program Name or Ancillary Text eere.energy.gov

The Parker Ranch installation in Hawaii

BUILDING TECHNOLOGIES PROGRAM

Energy Conservation Program for 

Appliance Standards:

NOPR Public Meeting for Refrigerators, 

Refrigerator-Freezers, and 

Freezers

October 14, 2010

Department of Energy

Energy Efficiency & Renewable Energy
2 2Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

• To present revised methodologies based on 

stakeholder feedback, and characterize results for 

analyses

• To discuss specific issues related to each analysis

• To seek input from attendees on methodologies, 

assumptions and data sources

• To describe remaining steps before issuance of Final 

Rule

Purpose of the Public Meeting

Introduction
3 3Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Issues for Comment

Introduction

Issue Box: DOE welcomes comments, data, and information 

concerning its analysis on residential refrigeration 

products. Throughout this presentation, issues that 

correspond to issues raised in DOE’s published material 

from this analysis are raised for discussion in boxes like 

this one. Nonetheless, comments are welcome on any part 

of DOE’s analysis.
4 4Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Background

• Final Rule published November 17, 1989 set performance 

standards effective January 1, 1993. (54 FR at 47916)

• Rule correction affecting three product classes published 

October 24, 1990. (55 FR at 42845)

• Second round final rule published April 28, 1997 for standards 

effective July 1, 2001. (62 FR at 23102)

• Analyses published in October 2005 to support priority setting for 

additional refrigerator rulemaking.

• Energy Independence and Security Act 2007 (EISA 2007) 

requires publication of updated standards by December 31, 2010 

to take effect January 1, 2014.
5 5Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Joint Comments

• Various groups representing manufacturers, energy, 

environmental, and consumer advocates submitted the Joint 

Comments August 12, 2010.

• The Joint Comments recommends specific energy conservation 

standards for refrigeration products that, in the commenters’ 

view, would satisfy the requirements under EPCA.

• DOE neither organized nor was a member of the group, but 

made its contractors available to perform data processing.

• Consistent with its legal obligations when developing an energy 

conservation standard, DOE is providing the public with the 

opportunity to comment on the proposed levels that DOE is 

considering adopting for refrigeration products, which mirror 

those recommended in the Joint Comments.
6 6Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Stakeholder Participation in the Rulemaking Process

Federal Register

notices

Framework

Document

Preliminary

Analysis NOPR Final

Rule

• Public meetings and oral comments

• Written comments on Federal Register notices, Technical Support 

Documents and Analytical Spreadsheets

• Data input from manufacturers and other interested parties. 

Stakeholder

participation

Today
7 7Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Comments from Participants

• Participants are invited to provide summary comments or 

statements

• Participants are invited to raise additional issues for discussion 

today

• The comment period closes on November 26, 2010
8 8Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Factor Analysis

1. Economic impact on consumers and 

manufacturers

Life-cycle cost analysis

Manufacturer impacts analysis

2. Lifetime operating cost savings Life-cycle cost analysis

3. Total projected energy savings National impact analysis

4. Impact on utility or performance Screening analysis

Engineering analysis

5. Impact of any lessening of 

competition

Manufacturer impacts analysis

6. Need for national energy 

conservation

National impact analysis

7. Other factors the Secretary 

considers relevant

Environmental assessment

Utility impact analysis

Employment impact analysis

The Energy Policy and Conservation Act (EPCA) directs DOE to consider seven 

factors when setting energy conservation standards
9 9Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Framework

Document ANOPR NOPR Final

Rule

NOPR Analyses

NOPR

Preliminary

Analysis

Final 

Rule

Proposed 

Standard 

Levels

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

Regulatory

Impact 

Analysis
1010Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Framework

Document ANOPR NOPR Final

Rule NOPR Preliminary

Analyses

Analyses for Final Rule

Final 

Review

Revise

NOPR

Analyses

Final 

Rule

Statute and Context
1111Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

NOPR Analyses

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups to 

Determine

Product

Price

Life-Cycle

Cost and

Payback 

Period Analyses

Market & 

Technology 

Assessment

Preliminary 

Manufacturer 

Impact Analysis

Proposed 

Standard 

Levels

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

Regulatory

Impact 

Analysis
1212Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Market & Technology Assessment Issues:

• Test Procedure

• Max-tech levels

• Product Classes

• Built-In products

• Automatic Icemakers

• Definition for Compact Products

Market & Technology Assessment
1313Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Schedule

• NOPR Published May 27, 2010

• Public Meeting Held June 22, 2010

• DOE is in the process of finalizing the Final Rule

Proposed Changes Affecting Measured Energy Use

• Compartment Temperature Changes

• Volume Measurement Method

• Adjustment of Current Standards to account for 

test procedure changes is discussed in the TSD

Market & Technology Assessment:

Test Procedure
1414Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Issue for Public Comment

Issue 23: Test Procedure Changes:

DOE requests comment on its adjustment of the current 

energy standards to account for test procedure changes. In 

particular, DOE requests comment on the approach used to 

adjust the standard levels to address compartment 

temperature changes and volume measurement method 

changes. 

DOE also requests comment and seeks information on whether 

any other proposed test procedure changes should be 

considered in setting the new standard—DOE seeks 

information quantifying the impact on energy use 

measurement of these additional test procedure changes.
1515Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

The max-tech efficiency levels are generally higher than 

max available efficiency levels.

Market & Technology Assessment:

Max Tech

Product Class Efficiency Level (Percent Energy Use Reduction)

DOE Analysis Max Available

3 36% 30%

5 36% 33%

7 33% 32%

9 44% 27%

10 41% 16%

11 59% 27%

18 42% 23%

3A-BI 28% 31%

5-BI 27% 27%

7-BI 22% 21%

9-BI 27% 27%

This reflects consideration of max-tech designs in the 

analysis that may not be cost-effective.

Information based on energy use not including icemaking energy use.
1616Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Product 

Class

Design Option

BLDC* Fan MotorsHeat Exchanger ImprovementThicker WallsVacuum Insulation Panels (VIPs)Variable Speed CompressorAdaptive DefrostVariable Anti-sweat Heater ControlIsobutaneRefrigerant

3     

5      

7      

9      

10    

11     

18    

3A-BI    

5-BI     

7-BI      

9-BI     

Market & Technology Assessment:

Max Tech

The analysis max-tech levels represent designs using all 

applicable design options for a given product class.
1717Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Issue 2: Max-Tech Levels:

DOE requests comment on the max-tech levels identified, and 

on the combinations of design options considered applicable 

to achieve max-tech designs. DOE requests that comments 

also address as appropriate the differences in applicable 

design options for different product classes.

Issue for Public Comment
1818Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Product Classes DOE is proposing to add are as follows.

• French-Door Bottom-Mount refrigerator-freezers with TTD 

ice service (product class 5A)

• Chest freezers with automatic defrost (product class 10A)

• All-refrigerators (product classes 1A, 3A, 11A, 13A)

• Products with automatic icemakers without TTD ice service.

• Built-in products.

Market & Technology Assessment:

Product Classes
1919Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Issues for Public Comment

Issue 3: Product Classes for Automatic Icemakers:

DOE requests comments on establishing product classes for 

refrigeration products with automatic icemakers and on the 

proposed approach to account for icemakers in the product 

class structure.

Issue 5: Additional Product Classes:

DOE requests comment on whether any additional product 

classes are required to fully address icemaking and built-in 

products.
2020Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Product Class Combination

Issue 6: Product Class Combination:

DOE requests comment on the proposal not to combine 

product class 2 (refrigerator-freezer—partial automatic defrost) 

with product class 1 (refrigerators and refrigerator-freezers 

with manual defrost) and the proposal not to combine product 

class 12 (compact refrigerator-freezer—partial automatic 

defrost) with product class 11 (compact refrigerators and 

refrigerator- freezers with manual defrost).

Clarification: DOE does NOT propose combining product classes 

1 and 2 and product classes 11 and 12.
2121Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Proposed definition for built-in products:

Built-in refrigerator/refrigerator-freezer/freezer means any refrigerator, 

refrigerator-freezer or freezer with 7.75 cubic feet or greater total volume and 

24 inches or less depth not including handles and not including custom front 

panels; is designed to be encased on the sides and rear by cabinetry; is 

designed to be securely fastened to adjacent cabinetry, walls or floor; and has 

sides which are not fully finished and are not designed to be visible after 

installation.

Market & Technology Assessment:

Product Classes

Issue 4: Separate Product Classes for Built-In Refrigeration Equipment:

DOE requests comment on the proposal to establish separate 

product classes for built-in refrigeration products. DOE also 

requests comment on the proposed definition for built-in 

products, including what changes, if any, are needed to 

strengthen it while not disqualifying any true built-in products, 

and whether the proposed 24-inch dimension specified in the 

proposed definition should be adjusted.

Issue for Public Comment:
2222Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

DOE proposes to eliminate the 36-inch height restriction 

for compact products. 

Market & Technology Assessment:

Product Classes

Issue 7: Elimination of 36-inch height limitation for compact products:

DOE requests comment on the proposal to eliminate the 

current 36-inch height limitation for compact products.

Issue for Public Comment:
2323Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Screening Analysis Issues:

• Compressors

• Vacuum-Insulated Panels

•Isobutane Refrigerant

Screening Analysis
2424Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

DOE considered the potential for insufficient supply of 

high-efficiency single-speed and of variable-speed 

compressors and has tentatively concluded that the 

supply base will be capable of ramping up to meet 

demand.

Screening Analysis:

Compressors

Issue for Public Comment:

Issue 8: Supply of high-efficiency and variable-speed compressors:

DOE requests comment on DOE’s findings regarding 

projections of supply of high-efficiency and variable-speed 

compressors. In particular, DOE seeks information that would 

confirm or cast doubt on DOE’s conclusions regarding 

compressor supply.
2525Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

DOE studied supply issues associated with VacuumInsulated Panels (VIPs) and tentatively concluded that 

suppliers will be able to ramp up production levels as 

needed to address potential demand.

Screening Analysis:

Vacuum-Insulated Panels

Issue for Public Comment:

Issue 10: Suitability of VIP technology as a design option:

DOE requests comment and information on aspects of VIP 

technology that affect its suitability for consideration as a 

design option. DOE in particular seeks any new information 

not already discussed or considered in the rulemaking.
2626Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

DOE concluded that expected limitations on allowed 

quantities of isobutane refrigerant make conversion to 

this refrigerant viable only for compact refrigerators.

Screening Analysis:

Isobutane Refrigerant

Issue for Public Comment:

Issue 9: Use of isobutane refrigerant as a design option:

DOE requests comment on the potential use of isobutane

refrigerant as a design option only for compact refrigerators.
2727Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

NOPR Analyses

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups to 

Determine

Product

Price

Life-Cycle

Cost and

Payback 

Period Analyses

Market & 

Technology 

Assessment

Preliminary 

Manufacturer 

Impact Analysis

Proposed 

Standard 

Levels

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

Regulatory

Impact 

Analysis
2828Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

DOE developed baseline energy use equations for all 

product classes based on data illustrating the impact of 

the key test procedure changes affecting measured 

energy use: compartment temperature changes and 

volume calculation method changes.

Engineering Analysis

Baseline Energy Use for New Test Procedure

AHAM 

Data

ESAF and 

VCAF factors

New Baseline 

Energy Use 

Equations

ESAF: Energy use ratio

VCAF: Adj. Vol. ratio

Energy = A AV + B

Anew = Aold ESAF VCAF

Bnew = Bold ESAF
2929Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

DOE raised the slopes of the baseline energy use equations for 

product classes 4, 5, and 5A. The intercepts were lowered to 

maintain equal average energy use.

Engineering Analysis

Slope Change

0

100

200

300

400

500

600

700

800

900

20 25 30 35 40

Annual Energy Usage (kWh/year)

Adjusted Volume (cubic feet)

Current Standard

Preliminary Analysis New Test Baseline

New Test With Adjusted Slope

Slope 4.91

Slope 11.3

Slope 5.51

• PC4 slope equal to PC7 

slope.

• PC5 slope equal to the 

average of PC3 and PC7 

slopes.

• PC5A energy use equal to 

PC5 plus the difference 

between PC6 and PC3 (the 

same approach used to set 

current PC5A energy levels 

established through 

exception relief)

Adjustment for product class 4
3030Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Issue for Public Comment

Issue 11: Slope adjustments for baseline energy use equations:

DOE requests comment on the approach used to develop 

Proposed Procedure Reduced Baseline Energy Use equations 

with adjusted slopes for product classes 4 (refrigeratorfreezers—automatic defrost with side-mounted freezer without 

through-the-door ice service), 5 (refrigerator-freezers—

automatic defrost with bottom-mounted freezer without 

through-the-door ice service), and 5A (refrigerator-freezers—

automatic defrost with bottom-mounted freezer with throughthe-door ice service) . DOE also seeks relevant data that would 

allow adjustment of the curve intercept so that the shipmentweighted average impact of the slope change would be neutral 

(i.e., zero change) with respect to energy use. DOE also seeks 

any additional information that would support similar 

development of adjusted-slope baseline energy curves for 

other product classes.
3131Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Engineering Analysis

NOPR Modifications

Parameter(s) Prelim. Analysis Changes for the Proposed Rule

VIP Surface Coverage Full product 

coverage, except for 

chest freezer walls.

Full coverage of doors, 50% coverage of 

cabinet, preference for coverage of freezer 

compartments, no change to exception for 

chest freezer walls.

VIP Effectiveness Full effectiveness as 

determined by the 

ERA energy model.

50% of ERA energy model effectiveness.

Cost Increase for 

Higher-Efficiency 

Components

Initial Analysis based 

on Preliminary 

Information

Adjusted based on additional information.

Conversion Costs for 

Increase of Insulation 

Thickness

Based on 

Manufacturing Cost 

Model

Increased due to Manufacturing Model 

Updates. Greater cost allocated to doors.

Heat Exchanger 

(Condenser and 

Evaporator) Size 

Increase

20% increase in the 

heat exchangers 

surface area.

Consider only where analyzed models have 

space. Direct modeling of heat exchanger 

performance based on geometry changes. 

Fan power increase for heat exchanger depth 

increases.

Standby Power for 

Variable Speed 

Controls

Not included. Addition of 1.5W load outside the cabinet for 

products not already having electronic control.

DOE modified its analyses in the NOPR phase based on 

comments and additional information.
3232Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Parameter(s) Preliminary Changes for the Proposed Rule

Variable Speed 

Compressor System 

Fan Control

Inconsistent 

selection of fan 

speed.

Fan operation at reduced speed, 50% power 

input consistent with cubic fan law.

Variable Speed 

Compressor 

Performance for 

Compact Products

Performance

according to 

compressor vendor 

data and ERA model.

Degradation of compressor capacity in ERA 

energy modeling based on performance data 

obtained from a manufacturer.

Isobutane Refrigerant Not considered Consideration of isobutane refrigerant for 

compact refrigerators, with 5% energy use 

reduction.

Variable Anti-Sweat 

Heater Control

Considered for 

product class 5*

Also considered for product class 7**

Baseline Anti-Sweat 

Heater Operation 

(Product Class 5* only)

Antisweat heaters 

considered French 

doors.

Baseline average wattage reduced for both 

directly analyzed products.

Variable Defrost 

Compressor Run time 

between defrosts

38 hours 24 hours; 

Adjustment also made in this value when 

converting to variable speed compressors.

* Refrigerator-freezers—automatic defrost with bottom-mounted freezer without through-the-door ice service

** Refrigerator-freezers—automatic defrost with side-mounted freezer with through-the-door ice service.

Engineering Analysis

NOPR Modifications, continued
3333Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Issue for Public Comment

Issue 12: Treatment of design options in engineering analysis:

DOE requests comment on its treatment of design options in 

the engineering analysis.
3434Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Issue for Public Comment

Issue 13: ERA energy modeling:

DOE requests comments, information, and data that would 

permit the adjustment of energy modeling inputs and/or results 

that would allow more accurate representation of the energy 

use impacts of design options using the ERA energy model.
3535Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use & 

End Use Load

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Equipment

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

NOPR Analyses

Proposed 

Standard 

Levels

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

Regulatory

Impact 

Analysis
3636Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Markups to Determine 

Equipment Price

Resulting Markup Multipliers

Refrigerators and Freezers

Markup Baseline Incremental

Manufacturer 1.26

Retailer 1.45 1.17*

Sales Tax 1.073

Overall 1.96 1.58

*Updated from 1.15 used in preliminary analysis, using U.S. Census 2002 Business Expenditure Survey (BES) 

Issue 12: Incremental markups:

DOE requests information regarding likely retailer responses 

to incremental changes in the CGS of appliances associated 

with the proposed energy conservation standards.
3737Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use & 

End Use Load

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Equipment

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

NOPR Analyses

Proposed 

Standard 

Levels

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

Regulatory

Impact 

Analysis
3838Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

 In order to distinguish top- and bottom-mount units that were not reported separately 

in RECS, DOE used AHAM data relationships between refrigerator-freezer product 

class and income to weight RECS households differently for these two product classes 

(PC 3 and 5).

 Similarly, AHAM data on relationships between built-in refrigerator ownership and 

income were used to weight RECS household data for these product classes.

 The average raw volume from RECS and sales data from NPD Group, Inc. differed for 

product classes 5 (bottom-mount ref/fzrs) and 7 (side-mount ref/fzrs) by 16% and 18% 

respectively. As a result, size distributions for these product classes were scaled 

upward.

Scaling of RECS data

Energy Use Determination

Issue 15: Income relationships and volume scaling of RECS data:

DOE requests comment on the weighting of the 2005 RECS 

sample using income relationships and volume scaling.
3939Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Usage Adjustment Factors

Energy Use Determination

 DOE responded to stakeholder feedback by developing a new 

energy use determination approach based on field metered data

 DOE used 1,652 data points from 7 metering studies obtained 

between 1994-2004 to develop regressions from which usage 

adjustment factor (UAF) functions were obtained for standard-sized 

products.

 UAF functions were applied to RECS household variables to 

estimate energy use for each refrigeration unit.

 Variables included heating and cooling degree days, location 

(heated space and/or basement), number of occupants, and unit 

age.
4040Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Energy Use Determination

Preliminary 

Sample Current Analysis Analysis 

Product Class Size Mean UAF Mean UAF 

Top-mount refrigerator-freezer 2,303 0.93 (0.82 to 1.04)* 1.23 

(PC 3) 

Bottom-mount refrigerator- 2,303 0.92 (0.81 to 1.02)* 1.09 freezer (PC 5) 

Side-by-side refrigerator- 1,026 0.94 (0.84 to 1.03)* 1.44 freezer wi th TTD (PC 7) 

Upright freezer (PC 9) 248 0. 85 1.37 

Chest freezer (pC 10) 369 0.89 1.48 

Top-mount built-in refrigerator- 2,303 0.94 (0.83 to 1.07)* N/A 

freezer (PC 3A-Bl) 

Bottom-mount built-in 2,303 0.96 (0.85 to 1.07)* N/A 

refrigerator- freezer (pC 5-BI) 

Side-by-side built-in 1,026 0.94 (0.84 to 1.03)* N/A refrigerator-freezer (PC 7-BI) 

Upright built-in freezer (PC 9- 248 0. 85 N/A BI) 

* Averages are based on lifetime distribution and include conversion to 2nd refrigerators. Range indicates 

average UAF in year I (minimum) and year 20 (maximum). 
4141Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Issue for Public Comment

Issue 16: UAF equations based on field-metered data:

DOE requests comments on its approach for developing UAFs 

using field-metered data.
4242Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use & 

End Use Load

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Equipment

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

NOPR Analyses

Proposed 

Standard 

Levels

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

Regulatory

Impact 

Analysis
4343Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Life-Cycle Cost and Payback Period 

Analysis

LCC and PBP Analysis Inputs

Baseline

Manufacturer

Cost

Std-Level

Manufacturer

Cost

Sales Tax

Installation

Cost

Total Installed

Cost

Energy Prices

 Energy Use

Equipment

Price

Lifetime

Operating

Expense

Annual Energy

Expense

Lifetime

Repair Cost

Discount Rate

Maintenance

Cost

Energy Price

Trends

Annual

Operating

Expense

Payback

Period

Life-Cycle

Cost

Manufacturer

Markup

From

Engineering

Analysis

(Price is a

function of

Efficiency)

From

Markups for

Equipment

Price

Determination

From

Energy Use

Determination

(Use is a

function of

Efficiency)

Consumer

Retail Price

Markup
4444Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Repair and Maintenance Costs

Life-Cycle Cost and Payback Period 

Analysis

Issue 17: Repair cost estimates:

DOE requests comment on the approach used for estimating 

repair costs.

Approach Estimated from component-level estimates of repair rate and unit 

repair cost

Sources Engineering Analysis, Commercial Refrigeration Equipment 2009 

Final Rule, Consumer Reports 2009 Annual User Survey, Best Buy 

Co. (2010), RSMeans 2010

Results Baseline annual repair costs vary with product class, from $1.43 to 

$21.90 per year

Incremental annual repair costs vary with product class, from $0.67 

to $2.58 per year
4545Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

• Base Case is used to project market share of higher efficiency 

products in the absence of standards

• Base Case Efficiency Distributions were determined using 2007 and 

2008 data supplied by AHAM.

– The change in the ENERGY STAR criterion for standard-sized 

refrigerator-freezers in 2008 was taken into account, allowing the 

ENERGY STAR market share for these products to return to pre-2008 

levels over time.

– ENERGY STAR levels in 2014 were assumed to be determined using a 

5-year payback period criterion.

• Standards Case Efficiency Distributions applied a “roll-up” approach 

used in the preliminary analysis, but assigned ENERGY STAR 

levels using the 5-year payback period criterion.

– For all product classes, the ENERGY STAR level vanishes for efficiency 

levels higher than 15% over the current baseline.

Base and Standards Case Efficiency 

Distributions
4646Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Issue for Public Comment

Issue 18: Base case efficiency distributions:

DOE requests comments on its approach for estimating basecase efficiency distributions.

Issue 19: Forecasting base and standards case efficiency distributions:

DOE requests comments on its approach for forecasting basecase and standards-case efficiency distributions.
4747Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Framework

Document ANOPR NOPR Final

Rule

NOPR Analyses

NOPR

Preliminary

Analysis

Final 

Rule

Proposed 

Standard 

Levels

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

Regulatory

Impact 

Analysis

DOE has no specific requests for comments on the following analyses: 

•Life-Cycle Cost Subgroup Analysis

•Trial Standard Levels

•Manufacturer Impact Analysis

•Employment Impact Analysis

•Regulatory Impact Analysis
4848Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Baseline treatment of regulatory 

emissions

• The emissions baseline is based on the 2010 Annual Energy 

Outlook. It accounts for regulatory emissions reductions through 

2008, including CAIR but not CAMR. Subsequent regulations, 

including the currently proposed CAIR replacement rule, the Clean 

Air Transport Rule, do not appear in the baseline.

• NOx emissions reductions are calculated using BT-NEMS for the 22 

states that do not participate in CAIR.

Issue 1: Regulatory emissions reductions:

DOE requests comment on its baseline treatment of regulatory 

emissions reductions for NOx.
4949Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Framework

Document ANOPR NOPR Final

Rule

NOPR Analyses

NOPR

Preliminary

Analysis

Final 

Rule

Proposed 

Standard 

Levels

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

Regulatory

Impact 

Analysis
5050Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Proposed Standards

The proposed standards, expressed as equations in terms 

of adjusted volume, are presented on pages 59471 and 

59472 of the NOPR.

Note that the equation for product class 5A-BI should 

read “9.72 AV + 595.5” for AV expressed in cubic feet.
5151Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Proposed Standards

Standard

-Sized 

Refrigera

torFreezers

Standard

-Sized 

Freezers

Compact

Products

Built-in 

Products

Proposed standard 

level 3 2 2 3

National Energy Savings 

(quads) 3.05 1.01 0.37 0.05

Net Present 

Value 

(2009$ 

billion)

3% 

discount 

rate

10.40 7.78 0.86 (0.46)

7% 

discount 

rate 0.41 2.12 0.25 (0.34)

Industry 

Net Present 

Value

2009$ 

million

(287.5) to 

(662.1)

(110.6) to 

(186.0)

(30.8) to 

(66.7)

(65.8) to 

(80.5)

% change (9.1) to 

(20.9)

(27.5) to 

(46.2)

(15.4) to 

(33.4)

(10.0) to 

(12.2)
5252Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Issue for Public Comment

Issue 20: Proposed standards for built-in products:

DOE requests comment on its considerations leading to the 

proposed standards for built-in refrigeration products, 

particularly regarding the projected negative net consumer 

impacts of the proposed standards.
5353Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Issue for Public Comment

Issue 21: Round off of energy standard:

DOE requests comment on the proposal for round off of the 

energy standard.

DOE is currently considering amending its test 

procedure to require round-off to the nearest kWh/year 

for energy use measurements. DOE has proposed roundoff of the energy standards to the nearest kWh/year for 

consistency. 
5454Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

Background

• DOE must publish an initial regulatory flexibility analysis if it cannot certify that 

the rule will not have a significant economic impact on a substantial number of 

small entities.

Findings

• DOE identified one small business manufacturer of residential refrigerators, 

refrigerator-freezers, and freezers

Regulatory Flexibility Act

Issue 22: Impact on small businesses and small manufacturers:

DOE requests comment on the regulatory flexibility 

determination, as well as any information concerning small 

businesses that could be impacted by this rulemaking and the 

nature and extent of those potential impacts of the proposed 

energy conservation standards on small residential 

refrigeration product manufacturers.
5555Building Technologies Program | Program Name or Ancillary Text eere.energy.gov

How to Submit Comments...

 Public Meeting – Oral comments will be captured in the transcript and 

become part of the public record.

 Written comments – Preliminary comment period open until November 26, 

2010. Reference docket #EERE-2008-BT-STD-0012 and/or RIN #1904-

AB79

Email: ResRefFreez-2008-STD- 0012@hq.doe.gov

Mail: Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mail stop EE-2J

1000 Independence Avenue, SW

Washington DC, 20585-0121

Courier: Ms. Brenda Edwards-Jones

U.S. Department of Energy

Building Technologies Program

950 L’Enfant Plaza, SW, Suite 600

Washington DC, 20024

Telephone: (202) 586-2945